Jeffries is committed to complying with the Privacy Act 1988 in relation to all personal information it collects. This commitment is demonstrated in this Policy. The Privacy Act incorporates the Australian Privacy Principles, and personal information held by Jeffries will be treated in accordance with those Principles.
This Policy sets out the broad controls which Jeffries has adopted to govern the way it collects and uses personal information, the circumstances in which it might disclose personal information to third parties, how persons can access their personal information held by Jeffries and what they can do if they are unhappy with Jeffries’s treatment of their personal information.
Who is Jeffries?
In this Policy, “Jeffries” refers to L F Jeffries Nominees Pty Ltd (ACN – 007 797 748) and each of its related bodies corporate.
This Policy applies to any individuals in respect of whom Jeffries currently holds, or may in the future collect, personal information.
This Policy applies to personal information. “Personal information” is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not.
In this Policy there are also references to “sensitive information”. “Sensitive information” is information or an opinion about a person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, or health, genetic or biometric information. Sensitive information is a subset of personal information.
What information is not personal information?
Information where Jeffries has removed any reference to a person, so that the person cannot be reasonably identifiable from the information, is not personal information.
Jeffries may use this information for its own purposes and commercial gain. For example, the fact that x users aged 30-35 have accessed a Jeffries website is not personal information.
How and when does Jeffries collect personal information?
Jeffries collects personal information in a variety of ways in the course of conducting its businesses, including:
• providing goods and services and related information to customers, and administering customer accounts;
• engaging suppliers, contractors and other personnel;
• responding to questions regarding our products and our business;
• interacting with people via our websites;
• conducting trade promotions and competitions; and
• security video surveillance at Jeffries sites.
The kinds of personal information collected and held by Jeffries include (depending on the circumstances) names, addresses and other contact details, details about a person’s work experience and other qualifications, date of birth, driver’s licence details, bank account details, photographs and video footage.
Where reasonable and practicable, Jeffries will collect personal information directly from the person and inform the person that this is being done.
However in some circumstances, it is necessary for Jeffries to collect personal information through third party service providers or agents (e.g. Jeffries customer information received from Jeffries Resellers), from a source of publicly available information (e.g. a telephone book) or from an employer (e.g. where a contractor provides personal information about its staff).
Personal information collected by Jeffries is held in a variety of formats, including hard copy format and on Jeffries’s computer systems.
If Jeffries receives personal information that Jeffries has not requested (unsolicited information) and Jeffries determines that Jeffries could not have collected that information under the Australian Privacy Principles if Jeffries had requested it, then Jeffries will destroy or de-identify the information if it is lawful and reasonable to do so.
Where practicable, you may deal with Jeffries anonymously or by pseudonym.
Collection of sensitive information
Jeffries will not collect sensitive information unless the person to whom it relates consents to the collection and the information is reasonably necessary for one or more of Jeffries’s functions or activities, except where the collection is required or authorised by law, is necessary to prevent or lessen a serious and imminent threat to the person’s (or another person’s) life or health or is necessary in relation to legal proceedings (current, anticipated or potential), or another permitted exception in the Privacy Act applies.
How does Jeffries use personal information?
The use to which we can put personal information depends on the reason for which it was collected.
Jeffries may use personal information for its primary purpose of collection (e.g. the delivery of goods to the person) or for any related secondary purpose that we could reasonably be expected to use the personal information for.
In certain circumstances, Jeffries may use personal information for promotional or direct marketing purposes. However, a person may at any time request Jeffries not to use their personal information for sending direct marketing material to that person. Such a request can be made by contacting Jeffries either in writing, by email or by telephone at the contact details below. There is no fee for making such a request.
Disclosure of personal information
Jeffries respects the privacy of personal information and we will take reasonable steps to keep it strictly confidential.
Jeffries will disclose personal information to third parties if it is necessary for the primary purpose of collecting the information, or for a related secondary purpose, if the disclosure could be reasonably expected (e.g. disclosure to a delivery contractor for the purpose of delivering goods ordered from Jeffries). Where such a disclosure is necessary, Jeffries will require that the third party undertake to treat the personal information in accordance with the Australian Privacy Principles.
Otherwise, Jeffries will only disclose personal information to third parties without the consent of the person to whom it relates if the disclosure is:
(a) necessary to protect or enforce Jeffries’s legal rights or interests or to defend any claims;
(b) necessary to prevent or lessen a serious threat to a person’s health or safety;
(c) required or authorised by law; or
(d) permitted by another exception in the Privacy Act.
Under no circumstances will Jeffries sell personal information without the consent of the person to whom it relates.
An individual Jeffries company may disclose personal information to a related Jeffries company, subject to the provisions of the Privacy Act. In such circumstances, the related company will only use the personal information for the same purposes that the disclosing Jeffries company is authorised to use the personal information for.
In accordance with the principles set out in this Policy, as part of its normal operations Jeffries transfers personal information to Jeffries companies and third parties.
Jeffries will take all reasonable steps to ensure that all personal information held by Jeffries is secure from any unauthorised access or disclosure. However, Jeffries does not guarantee that personal information cannot be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosures will not occur.
Jeffries will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purposes for which Jeffries is authorised to use it.
Accessing personal information
A person may request to access personal information about them held by Jeffries. Such a request must be made in writing to the address below.
Jeffries will grant a person access to their personal information as soon as possible, subject to the circumstances of the request.
A request to access personal information will be rejected if:
(a) the request is frivolous or vexatious;
(b) providing access would have an unreasonable impact on the privacy of another person;
(c) providing access would pose a serious and imminent threat to the life or health of any person;
(d) providing access would prejudice Jeffries’s legal rights; or
(e) there are other legal grounds to deny the request.
Jeffries may charge a fee for reasonable costs incurred in giving access to an individual’s personal information. The fee (if any) will be disclosed prior to it being levied.
Correcting personal information
Jeffries will take reasonable steps to ensure the accuracy and completeness of the personal information we hold. However, if a person believes that any personal information that we hold about them is inaccurate or out of date, then they should contact Jeffries in writing at the address below.
Jeffries deals with complaints via our internal data privacy complaint process, under which a Jeffries contact officer will be allocated to assess your complaint and respond to you within a reasonable timeframe. Jeffries takes all complaints seriously and any further action after our initial response to you will vary depending on the nature of your complaint.
Additional information regarding Credit Information
The types of credit information that Jeffries collects and uses for the purpose of assessing an application for commercial credit and administering a commercial account include:
• names, addresses and other contact details of accountholders and guarantors (both prospective and current);
• bank account details;
• driver’s licence details;
• financial information;
• information on the assets held by an individual.
Such information is collected from the relevant individual and from credit reporting bodies, as well as from publicly available information. Jeffries uses the information collected to create an internal credit assessment report.
Jeffries does not disclose credit information to credit reporting bodies, except for an individual’s identity in order to obtain a credit report from the credit reporting body.
Jeffries Privacy Officer
PO Box 60
Rosewater East SA 5013
Telephone: 08 8368 3555